A.04 - Tax law

Tax planning between Portugal and Brazil

Tax law applicable to individuals and companies with interests between Portugal and Brazil is an area of increasing complexity. The movement of people and capital, combined with tax regimes that change frequently, makes tax planning and ongoing tax support essential—both to avoid contingencies and to take advantage of legitimately available regimes.

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A.04

Estoril · Portugal

01 — Ongoing support

With professionalism and dedication

Piauhylino & Associados provides tax assistance to clients who live, invest, or carry out economic activity in more than one jurisdiction. We advise on the taxation of income, assets, and business transactions, with particular attention to Portugal–Brazil double taxation and the application of the Convention concluded between the two countries to avoid double taxation.

Our work combines preventive advice (regime analysis, structuring relocations, tax succession planning) with support in contentious matters (proceedings before the Portuguese Tax and Customs Authority, the Brazilian Federal Revenue Service, and in court). Monitoring recent changes, namely the IFICI, is an integral part of this work.

01

Relocation tax planning

Integrated analysis of the regime applicable to clients who change their tax residence between Portugal and Brazil.

02

IFICI and special tax regimes

Eligibility assessment and preparation of applications for the Tax Incentive for Scientific Research and Innovation (IFICI).

03

Portugal–Brazil Convention to Avoid Double Taxation

Practical application to the taxation of income, dividends, pensions, and capital gains.

04

Succession and wealth planning

Coordination between the Portuguese regime (Stamp Duty) and the Brazilian regime (ITCMD) in structuring the transfer of assets.

05

Tax litigation

Defence and representation in tax administrative and judicial proceedings in Portugal and Brazil.

Mission

To protect, with rigour and discretion, the interests of individuals and companies operating between Portugal and Brazil.

Vision

To be the benchmark in Portuguese-Brazilian transatlantic legal practice, recognised for technical excellence.

Values

Ethics, discretion, efficiency, and an individual approach to each case. No compromises.

02 — Why choose us

A practice
without borders.

01

Tax on both sides of the Atlantic

An integrated view of Portuguese, Brazilian, and European Union taxation, with attention to the Portugal–Brazil Convention.

02

Wealth and succession without borders

A team with hands-on experience in cross-border wealth and succession planning.

03

Always up to date with the changes that affect you

Systematic monitoring of legislative changes, namely regarding the IFICI and special tax regimes.

03 — FAQs

Frequently
asked questions

The most common issues in tax law matters. Each situation is individual—eligibility must always be assessed on a case-by-case basis.

Is the Non-Habitual Resident (NHR) regime still in force?

For new residents, the Non-Habitual Resident regime was replaced by the Tax Incentive for Scientific Research and Innovation (IFICI), effective in 2024. Those admitted to the NHR before its repeal retain the regime under the terms in which it was granted, for the remaining period. The specific situation must be assessed in light of the registration date and the applicant’s professional status.

As a general rule, taxation is levied in the country of tax residence on worldwide income, with the source country retaining, in certain cases, taxing rights. The Portugal–Brazil Convention allocates taxing rights according to the nature of the income. Correctly determining tax residence and coordinating reporting obligations in each country is therefore essential.

In Portugal, gratuitous transfers are subject to Stamp Duty, with an exemption for spouses, ascendants, and descendants. In Brazil, ITCMD applies, with rates and rules varying by state. The Portugal–Brazil Convention does not cover inheritance taxation, so planning must coordinate the transaction in both jurisdictions.

04 — Other areas

You may also
be interested.

05 — Contact

How can we
help you?

Do you have a tax matter between Portugal and Brazil? Contact us.

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